The Consumer Federation of America (CFA) and Consumers Union (CU) have been active participants in the media ownership proceeding through all four rounds of comments and in the closely related cable Horizontal Limits Proceeding. We respectfully petition the Commission to reconsider and revise each of the major rules affecting television broadcasting that the Commission has linked together in this omnibus rulemaking. The Order was developed through a flawed administrative process, reflects a partial, selective and faulty reading of the evidentiary record, applies faulty analytic reasoning that is inconsistent with generally accepted principles of antitrust and economic analysis, is riddled with internal contradictions, and is based on a misinterpretation of the law.

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